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Q&A: Billing office

HIPAA Weekly Advisor, July 13, 2009

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Q. Can we allow a covered entity’s billing office access to transcription files and medical records for billing purposes, or should billing office staff members request records if additional information is needed for billing purposes (such as to satisfy health plan documentation requirements before processing a claim)?

A. There is not a simple answer to this question. If billing office staff members need information from the transcription files or the medical record to complete a claim or a related patient bill before completing the billing process, you can allow access to transcription files and medical records—as long as access is limited to the minimum amount of PHI necessary to complete the billing process.

If billing office staff members already have sufficient information to submit a claim to a health plan and/or generate a patient bill, you should require the billing office to request any additional medical information rather than authorize billing staff members access to all transcription files or medical records.

This, again, should be limited to the minimum necessary and not comprise the whole patient record or transcript.

Editor's note: Chris Apgar, president of Portland, OR-based Apgar & Associates, LLC, answered this question. This is not legal advice. Consult your attorney regarding legal matters.

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